Mastromatteo is a member of the Ontario Medical Association and Chaired the Section on Occupational Health and the Committee on Public Health, He is a member ofthe Canadian Medical Association.

ASARCO denies that it failed to maintain a safe workplace and denies that Plaintiff was exposed to any asbestos and/or asbestos-containing products at its El Paso facility.

The Interrogatories herein seek information for a period of 70 to 80 years.

M yers, former Product and Production Manager for asbestos (Calidria) has provided much information.

The interrogatories request information going back many years and Garlock has found it difficult, if not impossible, to reconstruct or retrieve much of the information requested.

M yers, former Product and Production Manager for asbestos (Calidria) has provided much information.

Those employees .who chiefly provided the information used were as follows: Name/Dates Deoartment Rockwell Location Ms.

5 February 21, 19.84 c TO: ORC Asbestos Task Force .

., was exposed to any asbestos and/or asbestos-containing products at its El Paso facility.

Defendant objects to plaintiffs interrogatories to the extent that they seek information that is not within the personal knowledge of defendant's current employees.

Zum objects to the extent that these discovery requests seek information that includes proprietary information and trade secrets.

Asbestos Corporation, Ltd.

Dougherty has served as President of the Asbestos Information Association/n.a. since September 1975.

The interrogatories seek information going back many years and GARLOCK has found it difficult, if not impossible, to reconstruct or retrieve much of the information requested.

The enclosed information from H.K.